INTRODUCTION

At Adsan Law LLC (安晟律师事务所) (hereinafter referred to as “we”, “us” and “our”), we are committed to maintaining information relating to our clients, potential clients, and other relevant individuals with dealings involving us (hereinafter referred to as “you”, and “your” and “yours”) private and confidential, consistent with our professional obligations. 

This Policy is intended to assist you to understand the type of information we collect, how we use that information and the safeguards we have in place to protect that information and your privacy. 

PERSONAL DATA 

1. “Personal Data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access.

2. Examples of Personal Data which we may collect from you include:
   a.  name and identification information (such as your NRIC number);
   b.  contact information (such as your address, email address or telephone number);
   c.  nationality;
   d.  gender;
   e.  date of birth;
   f.  marital status;
   g.  photographs and other audio-visual information;
   h.  employment information (such as salaries, disciplinary records and performance reviews);
   i.  financial information such as credit card numbers, debit card numbers or bank account information;
   j. matter information such as litigation details (party names, witness statements), which may include sensitive data such as medical reports; and
   k. system-generated document and file metadata such as author and editor names, creation and modification dates, tracked changes and comments, email headers (senders, recipients and timestamps), IP addresses and device information to the extent such information has been disclosed to us.

3. Other terms used in this Policy shall have the meanings given to them in the Personal Data Protection Act 2012 (“PDPA”) (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA 

4. Personal Data may be collected:
   a.  from you directly;
   b.  from third parties and as agents on behalf of you where we or they have obtained the requisite consent, or as otherwise permitted or required by law;
   c.  through information publicly available;
   d.  in the case of an application for employment with us, from your employment application and the information and documents submitted; and/or
   e.  through our website, although such information is normally limited.

5. We may collect and use your Personal Data for any or all of the following purposes:
   a.  to facilitate the provision of our professional services and legal advice, and to support the administrative prioritisation and management of documents received in connection with our client matters through our triaging system and file management processes, for example by sorting incoming correspondence, court documents, and client materials for review by our lawyers and staff;
   b.  verifying your identity;
   c.  for conflict checking;
   d.  knowledge and relationship management purposes (including to develop and manage our knowledge management systems, organising seminars, events and to market and deliver our services);
   e.  complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
   f.  responding to complaints, queries and/or requests;
   g.  any other purposes for which you have provided the information;
   h.  transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
   i.  any other incidental business purposes related to or in connection with the above.

6. We may disclose your Personal Data:
   a.  where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
   b.  to third-party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.

8. By providing your Personal Data to us, you consent to our collection, use and disclosure of such Personal Data in accordance with this Policy, our Standard Terms of Engagement, your explicit and/or deemed consent, and/or as permitted or required by law. Consent to our collection, processing or disclosure of your Personal Data may be provided orally or in writing or may be deemed. This includes providing Personal Data to us in the course of our representation in legal proceedings or other matters in which we have been appointed to act on your behalf, which may subsequently require disclosure of your Personal Data as part of such representation.

9. Insofar as Personal Data of another individual provided by you to us is concerned, it is your representation to us that you have the necessary consent, permission and authority to allow us to collect, use and disclose such Personal Data for the purposes set out in this Policy.

10. For the purposes of discharging our professional or ethical obligations, we may from time to time allow or be required to allow third parties to access your Personal Data to process data on our behalf in connection with the conduct of our business or where such disclosure is in your interest or is otherwise permitted, required or authorised under the applicable law. In such situations, we will take reasonable steps to ensure that such third parties provide at least a level of privacy protection equivalent to that offered by us in this Policy prior to any access, processing or disclosure. 

WITHDRAWING YOUR CONSENT 

11. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time as it is withdrawn by you in writing.

12. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed in clause 5 above by submitting your request to our Data Protection Officer in accordance with clause 28.

13. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

14. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our professional services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 12 above.

15. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use, and/or disclosure without consent is permitted or required under applicable laws. 

ACCESSING AND CORRECTING YOUR PERSONAL DATA 

16. If you wish to:
    a. verify our use of your Personal Data;
    b. exercise your right to access, verify, amend, erase or block your Personal Data;
    c. submit a written request for us to cease to process your Personal Data; or
    d. make a complaint under this Policy, please submit your request to our Data Protection Officer in accordance with clause 28.

17. As permitted by applicable law, we may charge a reasonable fee to recover any incremental costs to process each access request. Your right of access is subject to the exceptions prescribed under the applicable law.

18. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA). 

SECURITY 

19. Your Personal Data is treated as private, confidential information which we strive to ensure remains protected and kept secure at all times. We will take all commercially reasonable steps in line with industry practice to protect your Personal Data, such as up-to- date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third-party service providers and agents only on a need-to-know basis. We cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.

20. However, as you are aware, no method of transmission over the Internet or method of electronic storage is completely secure, and extensive security measures may hinder efficient/prompt communication. To facilitate communication, email is a frequently used mode of communication and unless you object we may use unencrypted plain text emails for our communication with you. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA 

21. We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in accordance with clause 28. 

RETENTION OF PERSONAL DATA 

22. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

23. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes. 

TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE 

24. We may transfer your Personal Data to, or store or process it in, countries or territories outside of Singapore where this is necessary for the purposes set out in clause 5 above. This includes transfers to our third-party service providers (including providers of cloud computing, document management, artificial intelligence (including generative and agentic artificial intelligence) (“AI”), and automation (including robotic process automation) technologies, whether software- or hardware-based, and any successor or similar technologies) whose data centres may be located in the Asia-Pacific region or elsewhere. Where we do so, we will take such steps as are required under the PDPA and its regulations to ensure that the recipient is bound by legally enforceable obligations (such as contractual terms) and/or holds specified certification, so that your Personal Data continues to receive a standard of protection at least comparable to that provided under the PDPA. 

OUR WEBSITE 

25. There is no electronic means to automatically collect Personal Data from any visitor or user of our website. Information collected through our website will be the information voluntarily supplied by you if you contact us through our website. This information is normally limited to your name and email address and other information which you may voluntarily input. Our website may however contain links to other websites which may collect your Personal Data and we do not assume any responsibility for third-party website operators for the contents of such websites, and/or any Personal Data collected through such websites. We advise that you read the privacy policies of these websites before making an informed decision whether or not to provide your Personal Data to the websites’ operators.

26. When you visit our website our server will record your IP address together with the date, time and duration of your visit. The IP address enables us to identify which organisations have visited our website. We use this information to compile statistical data on the use of our website to track how users navigate through our site. We
    do this so we can evaluate and improve our site.

27. Our website may also allow third parties to download cookies to your device. These third-party cookies are not under our control.

DATA PROTECTION OFFICER 

28. You may contact our Data Protection Officer in writing or via email if you have any enquiries or feedback on this Policy and our procedures, or if you wish to make any request, at the address below:
    
    300 Beach Road
    Level 26 The Concourse
    Singapore 199555
    Email: dpo@adsanlaw.com

USE OF ARTIFICIAL INTELLIGENCE

29. We may, from time to time, use AI and generative artificial intelligence (“GenAI”) technologies (which, for the purposes of this Policy, include agentic AI, automation technologies such as robotic process automation, whether software- or hardware-based, and any successor or similar technologies), including tools provided by third-party service providers, to assist us in delivering our professional services, including for legal research, document review, drafting, analysis and knowledge management. Personal Data that you provide to us, or that we collect in the course of acting for you, may be processed using such technologies for the purposes set out in clause 5 above, and may be modified (for example, by extraction, summarisation, pseudonymisation or redaction) for use in conjunction with such technologies.

30. The Personal Data processed in this way is generally limited to the Personal Data contained in the documents, correspondence and instructions relating to the matter on which we are engaged. We use AI and GenAI technologies to support, and not to replace, the judgement of our lawyers. These technologies do not make decisions about you, and all outputs are reviewed by qualified professionals before being relied upon. 

31. We apply appropriate safeguards designed to protect Personal Data when using AI and GenAI technologies. These include: (a) restricting access on a need-to-know basis; (b) requiring relevant personnel and third-party service providers to be bound by legally enforceable obligations to protect our and our clients’ data including Personal Data in accordance with the relevant industry standards, not to retain your Personal Data beyond what is necessary or legally permissible, and not to use it to train or improve their own AI models; and/or (c) assessing data protection risks before deploying new tools and regularly reviewing our practices.

32. We will not disclose confidential client information containing your Personal Data to external AI or GenAI systems without appropriate safeguards and your prior consent obtained in accordance with this Policy. Where any such system processes or stores Personal Data outside Singapore, clause 24 above shall apply. 

33. You may request further information about our use of AI and GenAI technologies, or ask that such technologies not be used in connection with your Personal Data, by contacting our Data Protection Officer in accordance with clause 28 above. Clauses 11 to 15 above shall apply to any such withdrawal request, as applicable. 

EFFECT OF POLICY AND CHANGES TO POLICY 

34. In providing any Personal Data to us, you consent to our collection, use or disclosure of that information in accordance with this Policy.

35. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

36. We reserve the right to change, modify, delete or amend any part of this Policy from time to time without any prior notice and you are encouraged to make regular reference to this Policy. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.